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News ::
Greenwashing the FTAA? (english)
11 Mar 2003
Modified: 08:37:19 PM
Greenwashing the FTAA? Impossible.
(please forward widely)



**A Conference Presented by the Solidarity Network to Stop the FTAA (SNSF)**

Date: Evening, March 19, 2003
Location: McGill University, Leacock 26
Time: 6:30pm
Price: FREE TO ALL (any donations to defray expenses are appreciated)

The Solidarity Network to Stop the FTAA (SNSF) will be holding a conference entitled "Greenwashing the FTAA? - Grassroots Resistance to Corporate 'Environmentalism'" which will take place on the evening of Wednesday, March 19, 2003. "Greenwashing the FTAA?" will offer a corporate-free, people-powered forum to examine the environmental impacts of free trade from a grassroots level, to look at the problem of environmentalist agenda co-optation, and to explore avenues of resistance. The SNSF is a coalition of anti-FTAA activists mainly
from the Montreal area.

The conference is being mounted in response to another conference happening in Montreal on March 17-18 entitled "Greening the FTAA?" (website: The goal of that conference is, in the words of Environmental Law McGill (ELM) organizers: "to foster debate among all perspectives" - and the SNSF does not deny that valid efforts have been made to include critical voices. However trade and environment issues have become increasingly dominated by a corporate-friendly sustainable development (SD) agenda and the 'Greening' conference reflects this unfortunate reality.

The SNSF conference seeks to counter this trend. The SNSF wishes to restore emphasis on the basic principle that environmental issues must be resolved by the people whose livelihoods are most affected - not by corporate and institutional elites who hold increasing sway within the SD agenda.

Optimally, we are hoping that those who have the wherewithal and the time will attend both conferences. Time permitting, a segment of the SNSF event will be devoted to an open discussion of different views regarding conference process and biases based on people's experiences.

Scheduled to speak at the SNSF Conference are:

Judite Strozak - Movimento dos Trabalhadores Rurais Sem Terra (MST) (Landless Workers' Movement)

S'ra Desantis - Action for the Communtiy and Ecology in the Regions of Central America (ACERCA)

Jaggi Singh - No One is Illegal Campaign

Manuel Rozental - Canada-Colombia Solidarity Campaign

For further information on the SNSF "Greenwashing the FTAA?" conference, please contact:

Eric Squire
Organizer with the Solidarity Network to Stop the FTAA (SNSF -
ftaa-alert (at)
(450) 437-5044
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11 Mar 2003



DATE: November 15, 1990

SUBJECT: Criminal Investigation of Monsanto Corporation - Cover-up of
Dioxin Contamination in Products - Falsification of Dioxin
Health Studies.

FROM: Cate Jenkins, Ph.D., Chemist Regulatory Development Branch
(OS 332) Characterization and Assessment Division.

TO: John West, Special Agent in Charge Office of Criminal
Investigations Center U.S. Environmental Protection Agency
Building 53, Box 25227 (303) 236-5100 Kevin Guarino, Special Agent Office of Criminal Investigations National Enforcement Investigations Center, EPA

As per our meeting yesterday, I am summarizing information available to
me supporting allegations of a long pattern of fraud by Monsanto

Corporation. The fraud concerns 2,3,7,7-tetrachlorodibenzodi (dioxin)

contamination of Monsanto's dioxin-exposed workers. You indicated that you

would contact me regarding the specific documents which would be useful to

your investigation.


You stated that pursuing a criminal prosecution against Monsanto would

require a prior determination of the significance of the fraud. In order

for proceedings to be initiated by EPA, the fraud would need to have

affected the regulatory process at EPA and Monsanto would need to have

knowingly submitted the falsified data and health studies to EPA in order

to affect the regulatory process.

Monsanto has in fact submitted false information to EPA which directly

resulted in weakened regulations under RCRA and FIFRA since these

regulations do not take into account tetrachlorinated dioxin contamination

in trig, tetra, and pentachlorophenols, as well as 2,4-dichlorophenol and

its phenoxy acetate (2,3-D, a currently used herbicide). In addition,

Monsanto's failure to report dioxin contamination of the disinfectant in

Lysol has prevented any ban or other alleviation of human exposures to

dioxins in this product.

The Monsanto human health studies have been submitted to EPA by Monsanto

as part of public comments on proposed dioxin rules and Agency-wide dioxin

health studies are continually relied upon by all offices of EPA to

conclude that dioxins have not caused cancer or other health effects (other

than chloracne) in humans. Thus, dioxin has been given a lesser

carcinogenic potential ranking, which continues to be the basis of less

stringent regulations and lesser degrees of environmental controls. The

Monsanto studies in question also have been a key basis for denying

compensation to Vietnam Veterans exposed to Agent Orange and their children

suffering birth defects from such parental exposures. (1)

Monsanto would not be able to support a claim that independent

researchers were responsible for the falsifications, because Monsanto

personnel compiled all data utilized by these researchers. In addition the

National Institute of Environmental Health Sciences partially funded one of

the Monsanto studies in question providing a basis for charges of the

fraudulent use of governmental funds.


Monsanto covered-up the dioxin contamination of a wide range of its

products. Monsanto either failed to report contamination, substituted false

information purporting to show no contamination or submitted samples to the

government for analysis which had been specially prepared so that dioxin

contamination did not exist.

The earliest known effort by Monsanto to cover-up dioxin contamination of

its products involved the herbicide used in Vietnam Agent Orange (2,4, 5-

trichlorophenoxy acetate, 2,4,5-T). Available internal Monsanto

correspondence in the 1960s shows a knowledge of this contamination and the

fact that the dioxin contaminant was responsible for kidney and liver

damage, as well as the skin condition chloracne."

Early internal Monsanto documents reveal that samples of 2,4,5-T and

other chlorinated herbicides and chlorophenols submitted to the U.S.

Department of Agriculture in the 1970s were "doctored." In other words,

highly contaminated samples were not submitted to the government, and

Monsanto samples of penta tetra-, tetra-, tri-, dichlorophenol, and

associated herbicides never contained tetrachlorinated dioxins. These

analyses were subsequently adopted by EPA in a 1980 publication and were

used without any data from other sources as the basis for 1984 regulations

under RCRA. As a result, these regulations do not control the chlorophenol

phenoxy acetate products as acutely hazardous due to their contamination of

tetrachlorinated dioxins.

Monsanto also submitted assertions to EPA that process chemistry would

preclude the formation of tetrachlorophenol or its phenoxy acetate.

Evidence from the Kemner v. Monsanto proceedings revealed that this process

chemistry claimed by Monsanto was not always used. In fact, off-

specification dichlorophenol, known to be contaminated with

tetrachlorinated dioxin, was being used as a feedstock to make

pentachlorophenol and other chlorinated products. The result of this

alternate synthesis route is the introduction of dioxins as a contaminants.

EPA also relied on these "process chemistry" arguments by Monsanto as a

basis for not regulating most chlorophenols and 2,4-D for their

tetrachlorinated dioxin content.

Another Monsanto document introduced as evidence in the above proceedings

shows cross-contamination of a range of Monsanto products with

tetrachlorinated dioxins by the following mechanism: The same production

equipment is used without cleaning for all chlorinated phenolic products.

In 1984, when promulgating the dioxin regulations under RCRA, EPA was only

made aware of the cross contamination problem in the event that 2,4-D was

made on equipment previously used to make 2,4,5-T. Thus, EPA again was

subverted from promulgating adequate regulations for products other than

2,4-D that were cross-contaminated with dioxins.

Members of the Canadian Parliament recently directed investigations by

the Royal Canadian Mounted Police and government scientist into the dioxin

contamination of disinfectants such as Lysol containing Monsanto's

Santophen (ortho-dichloro-para-phenol), and directed laboratory analyses of

existing stocks. This disinfectant uses the ortho-dichlorophenol, discussed

above, as a feedstock, which would introduce any dioxins present into the

disinfectant. In a 1984 letter to the Canadian government, Monsanto

asserted that their disinfectant contained no dioxin. This was later

refuted by testimony by Monsanto's chemist.


As you indicated today, demonstrating criminal fraud in the

epidemiological studies performed by Monsanto on its dioxin-exposed workers

would necessitate bringing in appropriate groups in EPA capable of

performing scientific study audits.(3) You indicated, however, that NEIC

did not believe this would be a barrier to the investigation. The following

are a few key instances where obvious fraud was utilized in the conduct of

these studies:

Dr. Raymond Suskind at the University of Cincinnati was hired by Monsanto

to study the workers at Monsanto's Nitro, West Virginia plant. Dr. Suskind

stated in published studies in question that chloracne, a skin condition

was the prime indicator of high human dioxin exposures, and no other health

effects would be observed in the absence of this condition. Unpublished

studies by Suskind, however, indicate the fallacy of this statement. No

workers except those having chloracne were ever examined by Suskind or

included in his study. In other words, if no workers without chloracne were

ever examined for other health effects, there is no basis for asserting

that chloracne was "the hallmark of dioxin intoxication."(4) These

conclusions have been repeatedly utilized by EPA, the Veterans

Administration, etc., to deny any causation by dioxin of health effects of

exposed citizens, if these persons did not exhibit chloracne.

The results of Dr. Suskind's studies also were diluted by the fact that

the exposed group contained not only individuals having chloracne (a

genuine, but not the only effect of dioxin exposure), but also all workers

having any type of skin condition such as chemical rash. The workers could

have had no or negligible dioxin exposures, but they were included in the

study as part of the heavily exposed group. This fact was revealed only by

the careful reading of the published Suskind study.(5) Further, Dr. Suskind

utilized statistics on the skin conditions of workers compiled by a

Monsanto clerical worker, without any independent verification.(6)

Dr. Suskind also covered-up the documented neurological damage from

dioxin exposures. At Workers Compensation hearings, Suskind denied that the

workers experienced any neurological health effects. In the Kemner, et al.

v. Monsanto proceedings, however, it was revealed that Suskind had in his

possession at the time examinations of the workers by Monsanto's physician,

Dr. Nestman, documenting neurological health effects. In his later

published study, Dr. Suskind denied the continuing documented neurological

health effects suffered by the workers, falsely stating that symptoms "had


All of the Monsanto dioxin studies also suffer another fatal flaw. The

purported "dioxin unexposed" control group was selected from other workers

at the same Monsanto plant. An earlier court settlement revealed not only

that these supposedly unexposed workers were exposed to dioxins, but also

to other carcinogens. One of these carcinogens, para-amino biphenyl, was

known by Monsanto to be a human carcinogen and it was also known that

workers were heavily exposed.

Another Monsanto study involved independent medical examinations of

surviving employees by Monsanto physicians. Several hundred former Monsanto

employees were too ill to travel to participate in the study. Monsanto

refused to use the attending physicians reports of the illness as part of

their study, saying that it would introduce inconsistencies. Thus, any

critically ill dioxin-exposed workers with cancers such as Non-Hodgkins

lymphoma (associated with dioxin exposures), were conveniently excluded

from the Monsanto study.

There are numerous other flaws in the Monsanto health studies. Each of

these misrepresentations and falsifications always served to negate any

conclusions of adverse health effects from dioxins. A careful audit of

these studies by EPA's epidemiological scientists should be obtained as

part of your investigation.

The false conclusions contained in the Monsanto studies have recently

been refuted by the findings of a recent study by the National Institute of

Occupation Safety and Health (NIOSH). This NIOSH study, recently circulated

by Dr. Marilyn Fingerhut for review, found a statistically significant

increase in cancers at all sites in the Monsanto workers, when dioxin

exposed workers at Monsanto and other industrial locations were examined as

an aggregate group.(7)

Please do not hesitate to contact me regarding documents to support your

investigation, which include testimony and evidentiary documents from the

on-going Kemner v Monsanto litigation, earlier litigation in West Virginia

brought by the Monsanto workers, ongoing investigations by the Canadian

government internal Monsanto documents, as well as documentation of the

submission of the fraudulent data and studies by Monsanto to support the

rulemaking process under RCRA and other EPA authorities.

CC: Admiral E. Zumwalt

Senator Thomas Daschel

Congressman Ted Weiss

American Legion

National Vietnam Veteran's Coalition

Oklahoma Agent Orange Foundation

Independent International Agent Orange Network

Vietnam Veterans of New Zealand

Greenpeace, U.S.A.

Earth First

Natural Resources Defense Council

Environmental Defense Fund

Lennart Hardell, M.D., Ph. D.

Mikael Eriksson, M.D.

Olaf Axelson, M.D.

Friedaman Rohleder, M.D.

Mike Petruska Chief, Regulatory Development Branch

Carrol G. Wills, Acting Director, NEIC, EPA/Denver


(1) The American Medical Association, concerned about the veracity of one

of the Monsanto studies published in its journal, stated that a

reassessment would be undertaken if the outcome of appeal of the Kenmer v.

Monsanto litigation did not reverse the verdict impugning the credibility

of the Monsanto studies.

(2) You indicated that NEIC would be reticent to receive documents of this

nature suspected to be under a court protective order, but assured me that

you would pursue legal routes to obtain them independently.

(3) You should be cautioned regarding any consultation with Dr. Renate

Kimbrough at EPA regarding the review of the Monsanto studies. Dr.

Kimbrough was contacted by Monsanto during the Kenmer v. Monsanto

litigation and provided expert testimony, while an employee of the Centers

for Disease Control, on behalf of Monsanto. Dr. Kimbrough has provided

expert testimony on behalf of other defendant corporations responsible for

dioxin pollution even co-authoring papers with these defendants.

(4) Suskind examined only one worker without chloracne (Mr.Kiley), and

dismissed this individual's health complaints as being those of a


(5) Later studies by the Centers for Disease Control have demonstrated

that any manifestation of chloracne in humans is not correlated with the

blood dioxin levels. In other words, individuals with lower blood dioxin

have been observed to develop chloracne, those with higher blood levels did


(6) The deposition of Ms. Jan Young of Monsanto, previously under a

protective order, is in the process of release pursuant to a motion by

Greenpeace, USA.

(7) This NIOSH study does have a inherent design weakness that would

diminish the capability of detecting excess cancers. This is because

Monsanto and the other dioxin-producing companies were allowed to

independently select the group of dioxin-exposed workers to be studied by